Stibbe advises on the implementation of an intra-group financing structure involving a hybrid-profit participating loan

Stibbe advises on the implementation of an intra-group financing structure involving a hybrid-profit participating loan

Advising a major worldwide industrial player on the implementation of an intra-group financing structure involving a hybrid-profit participating loan that a Luxembourg holding company granted to a Belgian group company.

Our team obtained the first-of-its-kind ruling after the Belgian Ruling Commission lifted its ban on "hybrid PPL rulings" pursuant to the European Commission and the Code of Conduct Group’s dismissal of a complaint against such tax rulings.

Team

Related experience

Experience - Assisting the Walloon Transport Operator (OTW) on the creation of a brand new tramway network (11.7 km) including the construction of 21 stations and a new depot and the acquisition of trams in Liège, Wallonia. Proud to be part of the first major PPP project ever closed in Wallonia.

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